meta_id 3051352

On 9 April 2026, the Securities and Futures Commission (SFC) reprimanded and fined Impression Investment Limited HK$2 million for failing to diligently supervise its staff and maintain effective internal controls over staff trading activities. The SFC also prohibited Mr Liu Shan, a former director and responsible officer of Impression, from re-entering the industry for eight months, effective 2 April 2026 to 1 December 2026. The SFC's investigation found that between January 2016 and March 2021, Liu and another staff member engaged in personal trading contrary to regulatory requirements while responsible for making investment decisions for funds managed by Impression. Liu conducted over 2,500 personal transactions without obtaining prior written approval from Impression's designated officer and traded in the same securities on the same day as the funds he managed over 200 times, sometimes at more favourable prices. He participated in 12 initial public offerings through personal accounts, subscribing for the same IPO shares as the funds he managed, and failed to hold personal investments for the required minimum 30-day period on 29 occasions. The SFC determined that these activities breached the Fund Manager Code of Conduct and Impression's staff dealing policies. Although Impression maintained written staff dealing policies, they were neither implemented nor enforced prior to 2021. The SFC found that Impression failed to maintain effective procedures and controls to monitor staff personal trading activities and detect irregularities. The SFC attributed these failures to Liu's neglect in discharging his duties as responsible officer and senior management member. In mitigation, the SFC considered that Impression implemented regular post-trade monitoring of staff personal trades since 2021 and cooperated with the SFC in resolving concerns.